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As stated in NMFS Procedural Directive 32-110-01 "Use and Implementation of Electronic Signatures" NMFS program officials must perform a qualitative risk assessment consistent with the analytic framework called out in OMB M-01-04, "E-authentication Guidance for Federal Agencies." The OMB policy, and in turn, the NMFS Procedural Directive identify seven potential categories of impact from using e-signatures that include:

  • 1) Inconvenience, distress, or damage to standing or reputation to any party
  • 2. Financial loss to any party
  • 3. Agency liability
  • 4. Harm to agency programs or public interests
  • 5. Unauthorized release of sensitive information
  • 6. Personal safety
  • 7. Civil or criminal violations


Based on the risk assessment conducted by the FIS e-signature task force, the analysis focused on the following potential impacts listed below.

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